2004 Ruling 2004-0060891R3 - Linked notes - foreign property rules -- summary under Paragraph 206(1)(g)

Ruling that the issuance of notes by the Canadian branch of a foreign bank whose principal amount was linked to the return generated on "notional investments" by the holder in foreign investment funds, in which the bank had invested, would not constitute foreign property and that s. 245(2) would not be applied to such transactions.